Justia Indiana Supreme Court Opinion Summaries

Darryl Clifton was struck by a car driven by Ruby McCammack and suffered fatal injuries. At the time of the collision, Darryl’s father, Ray Clifton, was home watching television. After watching a news story about a fatal car crash, Ray drove to the scene of the accident, fearing the person involved in the collision was Darryl. When he arrived, the unsuccessful resuscitation efforts had ended, and Darryl’s body had been moved and covered with a white sheet. Ray sued McCammack for negligent infliction of emotional distress. The trial court granted summary judgment to McCammack, concluding that Ray failed to meet the circumstantial factors under the bystander test. The Supreme Court affirmed, holding that, as a matter of law, Clifton did not meet the bystander rule’s three circumstantial factors. View "Clifton v. McCammack" on Justia Law

The State charged eighteen-year-old Anthony Sharp, sixteen-year-old Blake Layman, and seventeen-year-old Levi Sparks with felony murder in the perpetration of a burglary. The jury found each defendant guilty as charged. In a consolidated appeal, Layman and Sparks claimed, among other things, that the felony murder statute was incorrectly applied in this case and that their sentences were inappropriate. The Court of Appeals affirmed the convictions but revised the sentences. The Supreme Court granted transfer, thereby vacating the Court of Appeals’ opinion. On transfer, Defendants invited the Supreme Court to revisit and overrule State v. Palmer and instead adopt the view expressed by the dissenting Justices in that case, namely, that a plain reading of the felony murder statute does not authorize the imposition of liability for murder where the defendant’s fellow perpetrator was the person killed. The Supreme Court reversed, holding (1) Palmer and its progeny continue to be valid, but the facts in those cases are significantly different from the facts here; and (2) the evidence was not sufficient to sustain a conviction for felony murder in the perpetration of a burglary. Remanded for further proceedings. View "Layman v. State" on Justia Law

The State charged eighteen-year-old Anthony Sharp, sixteen-year-old Blake Layman, and seventeen-year-old Levi Sparks with felony murder in the perpetration of a burglary. The jury found each defendant guilty as charged. On appeal, Sharp argued that the felony murder statute was incorrectly applied in this case, citing in support of his argument the Court’s opinion in Palmer v. State and arguing that the facts here were distinguishable. The Court of Appeals rejected Sharp’s attempt to distinguish the facts in this case from those in Palmer and ruled that there was no error in the application of the felony-murder statute to the facts of this case. The Supreme Court granted transfer, thereby vacating the Court of Appeals’ opinion. On transfer, Sharp argued that the precedent of Palmer and the application of the felony murder statute were in need of reconsideration. The Supreme Court reversed, holding (1) Palmer and its progeny continue to be valid, but the facts in those cases are significantly different from the facts here; and (2) because the Court reversed the felony murder convictions of both Layman and Sparks, and because Sharp is identically situated, his conviction for felony murder is reversed as well. Remanded for further proceedings. View "Sharp v. State" on Justia Law

Kentucky attorney Suzanne Cassidy represented Ernest Smith in Kentucky in a federal employment-discrimination lawsuit against his former employers, Dennis Boyer and Richard Smith, and other defendants. Attorney Cassidy subsequently dismissed Boyer and Richard from the suit. Thereafter, Boyer and Richard sued Ernest and Attorney Cassidy in an Indiana state court, alleging, among other tort claims, that the Kentucky suit was frivolous and constituted malicious prosecution. The trial court granted summary judgment in favor of Ernest and Attorney Cassidy, determining, as relevant to this appeal, that it lacked personal jurisdiction over Attorney Cassidy. The Supreme Court affirmed the trial court on the personal jurisdiction issue, holding that Indiana lacked specific jurisdiction over Attorney Cassidy because her conduct did not establish a substantial connection between herself and the state of Kentucky, and thus could not support personal jurisdiction. View "Boyer v. Smith" on Justia Law

After a jury trial, Defendant was convicted of one count each of aggravated battery, criminal confinement by removal, and battery resulting in serious bodily injury. Due to double jeopardy concerns, the trial court entered judgment for only the aggravated battery and criminal confinement counts. The court of appeals affirmed Defendant’s convictions and sentence. The Supreme Court granted transfer and reversed Defendant’s criminal confinement conviction and concurrent sentence, holding that there was insufficient evidence to support Defendant’s conviction for criminal confinement. View "Gibson v. State" on Justia Law

In 2007, the Brown County Board of Commissioners enacted an ordinance that established a county-wide fire protection district. In 2008, the newly elected Board enacted an ordinance purporting to dissolve the district. The Court of Appeals concluded that the Board lacked the authority to unilaterally dissolve the district by ordinance absent a petition process. In 2011, the Board amended the ordinance. Several county landowners sued various commissioners and the Board of Trustees, Brown County Fire Protection District seeking a declaration that the amendments were void. The trial court granted summary judgment to the landowners, concluding that the amending ordinance was not a valid exercise of the Board’s authority. The Supreme Court reversed, holding that the amended ordinance was a valid exercise of the authority of the Brown County Board of Commissioners. View "Anderson v. Gaudin" on Justia Law

A gas leak occurred at the home of William and Betty Kindle, customers of SCI Propane LLC and related entities (collectively, SCI), resulting in an explosion and fire that killed one of the Kindles’ family members, Stephan Frederick. Frederick was survived by his wife and his minor son. Frederick’s Estate filed a wrongful death suit against SCI. The jury apportioned sixty-five percent liability to SCI and thirty-five percent to the Kindles. Both parties sought attorneys’ fees under the Indiana General Wrongful Death Statute (GWDS). The trial court granted the Estate’s motion and denied SCI’s motion. The Supreme Court reversed the award of attorneys’ fees under the GWDS, holding that attorneys’ fees are not recoverable as compensatory damages under the GWDS when the decedent is survived by a spouse and/or dependents. View "SCI Propane, LLC v. Frederick" on Justia Law

JPMorgan Chase Bank, N.A. filed a post-judgment motion to intervene in this foreclosure action to protect its interest as assignee of a mortgage on the real estate of Deborah Walton and Margaret Walton. JPMorgan filed its motion three years after a final judgment foreclosing plaintiff Claybridge Homeowners Association’s judgment lien and six years after the suit began. The trial court denied the motion to intervene as untimely. The Supreme Court affirmed, holding (1) the motion to intervene was untimely because Plaintiff’s lis pendens notice, filed the day the suit began, provided constructive notice of Plaintiff’s foreclosure action; and (2) the notice was valid because it was based on Plaintiff’s enforceable, unrecorded judgment lien and because Plaintiff’s foreclosure action was not a personal claim but an in rem real estate action to enforce a judgment lien. View "JPMorgan Chase Bank, N.A. v. Claybridge Homeowners Ass’n" on Justia Law

General Contractor hired several subcontractors to assist in contracting an IMAX theater. After the theater was completed and three of the subcontractors (“Subcontractors”) had not been paid in full for their services, the Subcontractors filed mechanic’s liens against the IMAX property and sued the General Contractor to foreclose on their respective liens in the amount due on their contracts. The trial court awarded the Subcontractors judgments against the General Contractor and awarded attorney’s fees. At issue in this case was whether, under Indiana’s mechanic’s lien statute, the Subcontractors were entitled to collect attorney’s fees incurred in foreclosing on their liens from the General Contractor, which posted a surety bond and filed an undertaking obligating it to pay attorney’s fees upon recovery of a judgment against it. The Supreme Court affirmed the trial court’s fee award, holding that the trial court did not abuse its discretion in awarding the Subcontractors attorney’s fees incurred in their foreclosure suits under the circumstances of this case. View "Goodrich Quality Theaters, Inc. v. Fostcorp Heating & Cooling, Inc." on Justia Law

Junior creditor Car-X Associates Corporation sued a mortgagee to foreclose on a lien. In addition to the mortgagee, Car-X’s complaint named senior creditor Huntington National Bank as a defendant to answer as to any interest it may have in the real estate. When Huntington failed to timely respond to the complaint and summons Car-X obtained a default judgment against Huntington. Huntington moved to set aside the default judgment under Indiana Trial Rule 60(B)(1) because of its excusable neglect and under Indiana Trial Rule 60(B)(8) because such relief would be just and equitable under the circumstances. The trial court denied the motion. The Supreme Court (1) affirmed the trial court’s denial of Huntington’s motion to set aside the default judgment for excusable neglect; but (2) remanded to the trial court to reconsider whether equitable reasons support granting Huntington’s motion under Trial Rule 60(B)(8), especially in light of Huntington’s meritorious defense to the underlying foreclosure suit, the substantial amount of money involved, and Car-X’s lack of prejudice from the delay. View "Huntington Nat’l Bank v. Car-X Assocs. Corp." on Justia Law